Document gaYMJqJE3bv7Rw99K0GJyp37L

Michael J. Sweeney Attorney-at-Law Law Offices of DICKIE, MCCAMEY & CHILCOTE Philadelphia 215/925-2289 A ProfessionalCoRporation Two PPGPlace, Suite 400 Pittsburgh, Pennsylvania 15222-S402 WWW DMCLAW com Tel. 412/281-7272 Fax. 412/392-5367 NeW Jersey 609/844-7744 Ohio 740/284-1682 West Virginia ,304/233-1022 September 19, 2000 2.Q7\ f\ - 412/392-5231 sweenem@dmclaw.com Wells Watson, Esquire Baggett, McCall & Burgess 3006 Country Club Road Lake Charles, LA 70606-7820 Via Federal Express #101494845 Re: Ross v. PPG Industries, Inc. Our File No.: 108520 Dear Mr. Watson: Enclosed please find copies of the Marcus Key deposition and exhibit documents and the Busey documents. Very truly yours, :al Enclosures Antoinette Lamonde Secretary to Michael J. Sweeney Memo re Busey Documents received from Sweeney under cover letter dated 9/19/00 EPL 303-001 Folder 1 "IBT Mice Inventories" EPL 1-14: This is a collection of spreadsheet information on the 1600 mice in the study at IBT; On the left hand column are the organs and areas of the mice bodies of interest; On the top are the mice study numbers (appear to be 1600 mice studied); the data is entered into the cells by letters "S", "B", and "W" EPL 21-43: Same type of spreadsheet, but there are tallies along the y-axis for the organs with heart (64), kidneys (69), liver (70), lung (70) and spleen (68); along the xaxis are small numbers with "pm" written below them - could this be a measurement of the parts per million each animal was exposed to? Also along the x-axis are "X"s placed through both of these rows with large question marks above them - could this be to indicate death? EPL 44-53: Same with additional notation of male and female symbols EPL 54-83: Slightly different spreadsheet; separated the Test Groups into C, T-l, T-2, T-3 and T-4; Same organs down the y-axis and animal no. along the x-axis; have a totals column all the way to the left; dated in March of `78 EPL 84-93: Same spreadsheet info EPL 303-001 Folder 2 "IBT Rat Inventories EPL 103-142: Slightly different spreadsheet like one at EPL 54 EPL 143-205: More spreadsheet info EPL 303-001 Folder 3 "IBT Hamster Inventories" EPL 206-280: Same spreadsheet info; But see EPL 227 "Potential Plans for Vinyl Chloride" EPL 303-001 Folder 4a EPL 281-377: 23-Month Status Summary to MCA "Chronic Vapor Inhalation Toxicity Study With Vinyl Chloride (Ethylene derived) In Albino Rats, Albino Mice and Golden Hamsters" dated 9/23/75 EPL 303-001 Folder 4b EPL 378-432: Epidemiological Study of VC Workers Final Report by EEH dated January 1978 EPL 433-483: Final Report of Audit Task Group on Lifetime Inhalation Study on VC at IBT; contains CMA minutes form early `70s EPL 484-572: Evaluation of the Environmental Toxicant VC and VDC Progress Report NO. 8 July 1-31, 1975 for NIEHS EPL 573-731: Same; Final Report July 1975 through June 1977 for NIEHS EPL 733-765: Same; Progress Report 1/1/76-3/31/76 for NIEHS EPL 766-831: Additional Evaluation of The Environmental Toxicants VC and VDC Jan '76 through Dec '78 for NIEHS EPL 833-922: Life span Oral Toxicity Study of VC in rats CENTRAAL INSTITUUT VOOR VOEDINGSONDERZOEK, dated October `78 EPL 923-986: Vinyl Chloride Summary Report "Toxicology, Carcinogenicity and Reproductive Effects of Single and Multiple Exposure to VC in Rats and Mice EPL 987-1073: Summary Report EPL 303-001 Set 1 of 5 Correspondence EPL 1074-1093: apparent info germane to plaintiffs' '97 subpoena in Ross EPL 303-005 Set 2 of 5 "Report" EPL 1094-1137: EPL "Pathology Report On the Brains from Mice, Hamsters, and Rats Exposed to Vinyl Chloride In IBT Study" dated 5/14/80 ^ EPL 303-005 Set 3 of 5 "Rough Draft Data and Notes" EPL 1138-1268: See EPL 1181 for Rough Draft of above; See EPL 1224 for Notes on IBT study "Observations Made from the Pathology Sheets" EPL 1270-1312: "Pathology Report on the Brains From Mice, Hamsters, and Rats Exposed to Vinyl Chloride in IBT Study" dated 5/14/80 EPL 303-005 Set 5 of 5 "Meetings" EPL 1313-1329: Handwritten notes re brain tumors in IBT rats; also "investigation of Apparent Increased Prevalence of Brain tumors in a US Chemical Plant" part of a presentation to WORKSHOP ON BRAIN TUMORS IN THE CHEMICAL INDUSTRY NEW YORK ACADEMY OF SCIENCES, OCTOBER 27, 1980 EPL 303-001 Set 1 of 10 "Correspondence" EPL 1330-1513: Bob West Associates, Inc. report entitled "Review and Audit of IBT No. .. .Chronic Vapor Inhalation Toxicity Study with VC ..."; also there are many MCA minutes here. EPL 303-001 Set 2 of 10 "EPL's Inventory Comments" EPL 1514-1615: "Vinyl Chloride Brain Examination" EPL 303-001 Set 3 of 10 "EPL's Paraffin Block Inventory (Material Examined)" EPL 1616-1717: "Vinyl Chloride Brain Examination" EPL 303-001 Set 4 of 10 "EPL's Micro-Slides Inventory (Material Examined)" EPL 1718-1818: Vinyl Chloride Brain Examination ... Microscope Slides EPL 303-001 Set 5 of 10 "EPL's Wet Tissue Inventory (Material Examined)" EPL 1820-1921: Vinyl Chloride Brain Examination ... Wet Tissue EPL 303-001 Set 6 of 10 "IBT Inventories" EPL 1922-1990: Decent looking data, including summary of tissue samples EPL 303-001 Set 7 of 10 EPL 1991-2043: "Vinyl Chloride Pathology Report" dated 1/9/79 . / EPL 303-001 Set 8 of 10 "Bound Rough Draft of Report" EPL 2044-2095 EPL 303-001 Set 9 of 10 "Rough Draft Data and Notes" EPL 2096-2178 EPL 303-001 Set 10 of 10 "Reference Material" EPL 2179-2337